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November 19 2000 Dear Governor Ventura, I have a major problem with my small business that I would like to ask for your help in solving. I am starting a fish farm, and aquatic weeds are an expensive problem. I manage my ponds intensively and this requires moving the fish several times each summer. The fish I raise are sold when they are still small but the weeds prevent me from harvesting the fish when I need to get them harvested. Our season is short and in order to get a second crop from my ponds I must harvest the first crop within a couple weeks of schedule. This year so far I have spent (wasted) over 20 hours extra trying to harvest just two of my ponds because of weeds. Not only that but I wasn't able to completely harvest the ponds and this will reduce the harvest this fall. Plus I killed a large amount of fish fry because they were tangled in the weeds. One pond that should have been harvested three weeks ago is still untouchable. The crop in that pond went from excellent to poor. I now am in danger of losing my entire years crop of smallmouth bass because the herbicide killed too much vegetation. This is a major source of my income for this year. I have just learned that this is exactly what happened to a fish farmer near Alexandria last year. It cost him many thousands of dollars worth of fish. Currently, I am forced to use herbicides but they are risky to use because if too many plants die at once, the decomposing plants can use up all the oxygen in the pond and kill all the fish. My fish depend on the zooplankton that I cultivate in the ponds and herbicides can cause this essential food source to disappear. Herbicides are also very expensive. A biological solution exists, that is both safe and effective, but I cannot get the DNR to even discuss the issue. The solution is triploid (sterile) grass carp. I have requested a permit to import them twice but the answer has been no. The arguments given are not supported by current scientific information. While it is true that grass carp are an exotic species the fish I would like to import are sterile because they have an extra set of chromosomes. This renders them highly unlikely of producing viable sperm or eggs. According to Allen et al. (1986), the probability of a male triploid grass carp successfully mating with a normal female grass carp is 4 x 10 (-11). Put another way, a person is 300+ times more likely to win the Powerball than for this fish to produce viable offspring if paired with a normal female. None of the females I would be importing would be normal. I have yet to find any information that says a female triploid grass carp is even capable of producing viable eggs. My ponds are static water and since grass carp require moving water to stimulate spawning the possibility of successful reproduction becomes almost too small to calculate. Then there is the fact that grass carp eggs require moving water for 2-3 days in order to stay suspended long enough to fully develop. Again, my ponds are static water and would not give the needed environment for the eggs to hatch. Add this to the facts that my ponds are man-made, sit in a dry cornfield, are filled with well water, and have no connection to any public water. The probability that these fish represent a threat to the environment is a moot point. The fish are twice certified using a United States Fish and Wildlife Service (USFWS) approved method. The farmer certifies the fish once and then later rechecks the same fish in front of a trained USFWS employee. Large orders are rechecked using a subsample, but when a small lot is purchased, as I would order, each fish is individually double-checked. I also have a contact with the United States Geological Service that has offered to recheck the fish a third time using flow cytometry. This method is also a highly respected way of determining ploidy (sterility). I would not request a permit to import these fish if I thought there was any chance that they could escape and become established in Minnesota. But, clearly certified triploid grass carp represent no threat whatsoever to our native fish populations or the environment. The DNR has even admitted this in an e-mail. Whenever I have even mentioned this fish to people in the DNR you can just about see their hands go up to cover their ears and they refuse to even discuss it. I can find no biological reason to deny the permit to import this sterile fish and I believe it is entirely a political decision designed more to make the life of a bureaucrat easier than it is to protect our natural resources. It is hurting my small but growing business. I would appreciate your attention to this important matter and welcome any assistance or suggestions that might help me get this resolved. Maybe you could ask Commissioner Garber to look into this issue? I've lost faith in the Fisheries division to view this issue objectively since they are obviously ignoring the science. In fact, I don't believe the division was even aware of the USFWS procedure that allowed individual fish to be tested in front of the USFWS when they made the arbitrary rule prohibiting triploid grass carp. I have attached copies of the USFWS procedure, DNR communications and the Allen paper for your convenience. Thank you for your time in resolving this important matter.
Sincerely, John Reynolds Midwest Fish and Crayfish 26385 County Road 3 Merrifield, MN 56465 (218) 765-3030 fishes@brainerd.net
P.S. The best time to reach me is between 7-8:30 am or in the evening. |